The Privacy Policy describes how Stewby’s Inc and its subsidiaries and affiliated entities (collectively “Stewby’s” “we” and “us”) process personal information about you. This Privacy Policy applies when you engage with us online or offline, such as when you visit or use our websites or mobile applications (each a “Site” and collectively “Sites”), contact our customer service team, engage with us on social media, join our loyalty program, make a reservation or visit one of our locations, purchase our products or gift cards, or otherwise interact with us. If you need to receive this Privacy Policy in a different format, please contact us at stew@stewbys.com.

BY USING THE SITES OR OTHERWISE PROVIDING US WITH YOUR PERSONAL INFORMATION, YOU ARE AGREEING TO THE PROCESSING OF INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.  PLEASE READ IT CAREFULLY.

Contents

Categories of Personal Information We Collect

The type of information that we collect depends on your interaction and relationship with us.  We collect the below categories and types of personal information with your consent or as otherwise required or permitted by law.

  • collect full name, email address, address, telephone numbers, Internet protocol address, social media usernames, account usernames and passwords, signature, social security number, driver’s license number, passport number, and other security information for authentication and access.Identifiers. We
  • Personal Characteristics or Traits. We collect date of birth, gender, age, nationality, racial or ethnic origin, religion, marital status, citizenship status, military or veteran status, and disability information.
  • Financial Information. We collect tax identification number, financial or bank account information, tax-related information, wire instructions, payment card number, payment card expiration date and CVV code, card or account security details, and billing address.
  • Commercial Information. We collect records of products or services purchased, obtained, or considered.
  • Internet or Electronic Usage Data. We collect data related to network and website interaction history, IP address, website cookie information, interaction with advertisements, and browsing time.
  • Audio/Visual Data. We collect audio, electronic, photographic, visual, or similar data including videos, photographs, or audio recording.
  • Geolocation Data. We collect geolocation data including the general region or area from which you access our Sites.
  • Professional or Employment Information. We collect your job title, business contact details, and company entity. If you apply to work with us, we collect job application details such as your employment history, resume, and references as well as information on any relevant certifications or licenses.
  • Education Information.If you apply to work with us, we collect education history.
  • Sensitive Personal Information. We collect government issued identification numbers (e.g., social security, driver’s license, state identification card, passport number), and Account Log-In (e.g., username and password to online account with us).
  • Inferences: We use information from the categories of personal information described above in order to create a profile about you, to reflect your preferences, characters, behavior, and attitude.

 

Sources Of Personal Information

We collect personal information in the following ways:

  • Directly from you. We collect identifiers, financial information, personal characteristics or traits, commercial information, professional or employment information, education information, and sensitive personal information that you provide directly to us.
  • When you visit our locations. When you visit our offices or locations, we collect identifiers and audio/visual data.
  • Automatically. When you access our Sites, we collect identifiers, geolocation data, and internet or electronic usage data using tools like browser cookies.
  • From third parties, vendors and service providers: We may receive identifiers, financial information, personal characteristics or traits, commercial information, professional or employment information, education information, and sensitive personal information from our service providers, vendors, and other third-parties.
  • Social media platforms. Depending on the information you choose to share and your privacy settings, we may collect contact information, identifiers, audio/visual data, personal characteristics or traits, commercial information, professional or employment information, education information, sensitive information, internet or electronic usage data, and inferences. Based on the way you have set your privacy settings on your social media accounts, most social media platforms, like Facebook, analyze data about how you interact with our Sites and combine it with information on other users to provide us information about you. In addition, we may receive information about you if other users interact with us on social media and information about you is visible to us, for example the fact that you are “friends” or other public-facing profile information.

Purposes for Collecting Personal Information

We use your personal information for the following business and commercial purposes:

  • Transactional. We use identifiers, financial information, and commercial information to: (i) allow you to purchase and receive tickets, gift cards, products, and services that we offer; (ii) allow you to make a reservation with us or check-in to one of our locations or properties; (iii) consider your application to operate a franchise; (iv) communicate with you; (v) provide you with customer or guest assistance; and (vi) provide supporting business activities such as billing and collections, procurement, and tax related activities.
  • Loyalty Clubs. We use identifiers, financial information, personal characteristics or traits, sensitive information, and inferences to enroll you into our rewards programs and loyalty clubs, create your online account, and administer your rewards account and benefits.
  • Background Check. If you apply to become a member of certain of our loyalty programs or to operate a franchise or to obtain a line of credit at one of our casino’s, we may require you to complete a background check to verify your identity, check for criminal history, check your credit worthiness, and confirm the validity of your application. We use identifiers, personal characteristics or traits, professional or employment information, non-public education information, and sensitive information to enable the completion of the background check.
  • Combination of Data. We combine information we obtain from different sources with publicly available information, including to create inferences about you. For example, we may combine information that we have collected offline with information we collect online. We combine information that we have collected across other third-party sites. We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have.
  • Recruiting and Hiring. We use identifiers, audio/visual data, professional or employment information, education information, financial information, and inferences to make informed decisions on recruitment and assess your suitability for the role, communicate with you about your application, respond to your inquiries and schedule interviews, and to reimburse you for any agreed expenses incurred in the application process.
  • Analytical. We use identifiers, usage data, geolocation data, commercial information, and inferences to analyze preferences, trends, and statistics.
  • Marketing and Promotional. We use identifiers, financial information, geolocation information, and internet or electronic usage data to improve our marketing efforts, for prospecting of new customers, for customer relationship management, for customer engagement, to administer sweepstakes and promotions, to send you our newsletters, and to provide you with information about us, including personalized marketing communications.
  • Maintenance and Improvement of our Website and Systems. We use internet or electronic usage data and geolocation data to improve our Sites and systems, provide and maintain functionality on our Sites and systems, and help us diagnose technical and service problems and administer our Sites and systems.
  • Develop and Improve Our Products and Services. We use identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information to help us develop new products and services and to improve and analyze our existing products and service offerings.
  • Security and Fraud Prevention. We use identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, education information, professional or employment information, and sensitive information to: (i) protect our Sites, premises, assets, systems, products, services and intellectual property; (ii) protect us, our affiliated companies, our employees, our carriers and others from fraud, theft, and other misconduct; (iii) conduct vendor due diligence; and (iv) detect and prevent fraud, theft, and misconduct including by verifying the identity of those we are conducting business with.
  • Legal: We use identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, education information, professional or employment information, and sensitive information to comply with our legal obligations, including reporting requirements, and defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.
  • Other Purposes: We may use identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, education information, professional or employment information, and sensitive information for other reasons we may describe to you.

How We Disclose Personal Information

We disclose personal information in the following circumstances:

  • Service Providers: We may share personal information with vendors and service providers who support the operation of our services, website, and our business and who need access to such information to carry out their work for us (including, for example, cloud hosting providers, analytics, payment processing, background and credit checks, attorneys, accountants, order fulfillment, email delivery, marketing, insurance, internet service providers, operating systems and platforms, recruiting vendors, credit verification, maintenance and customer support services). In some cases, the vendor or service provider may directly collect the information from you on our behalf.
  • Affiliates: We may share personal information with and among our parent company, subsidiaries, affiliates, or their successors or assigns.
  • Marketing/Analytics/Advertising Partners: We may share personal information with third party marketing, analytics or advertising partners, including social media platforms and networks, who provide analytics or marketing and advertising services to us.
  • Government Entities: We share information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us.
  • Corporate Transaction Recipients: We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations; or (iii) are soliciting or accepting investments.
  • Other Reasons: We may disclose personal information for other reasons we may describe to you, including if you consent to the disclosure or direct us to disclose your information. 

How Long We Keep Personal Information

We will retain and use your information for as long as we need it to provide you services or products, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. 

Where we process personal information for marketing purposes, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing so that we can respect your request in future. We use the following criteria to determine retention periods:

  • how long the information is needed to provide our services and operate our business;
  • whether there are contractual or legal obligations that exist that require us to retain the information for period of time;
  • whether any law, statute, or regulation allows for a specific retention period;
  • whether an individual has agreed to a longer retention period;
  • whether the data is considered to be sensitive data, and
  • what the expectation for retention was at the time the data was provided to us.

Cookies, Analytics, and Other Tracking Technology

Cookies and Tracking Technology. When you access the website, we (and third-party companies we work with) may collect and store certain information by using technologies such as server logs, cookies, web beacons, clear gifs, tags, e-tags, flash cookies, log files, pixels, code, JavaScript packages, mobile advertising IDs (such as Facebook cookies or Google’s Advertising ID), cross-device linking, and similar technologies.  The information collected includes information about your activities on our Sites, IP address, browser or operating system type and version, device IDs, and demographic or inferred-interest information, as well as information or communications you have submitted to us through the Sites. 

We use this information to understand general usage and volume statistics, how users navigate to and around our Sites, what content is viewed or accessed, and which products and services have been obtained.  We also use these technologies to keep track of your preferences and profile information.  We also use these technologies to allow third parties to provide analytics and advertising services and serve advertisements on our behalf across the Internet and in mobile applications. For example, our advertising partners may use the fact that you visited our Site to target advertising to you on other websites and mobile apps on your current device or on other devices you use.  They may match your browsers or devices if you log into the same online service on multiple devices.  These third parties’ partners may use this information for our and their own advertising, analytics, attribution, and reporting purposes.  To learn more about interest-based advertising, tracking technologies, and how to opt out, please visit http://www.aboutads.info/choices.  You can disable the sharing of your personal information for cross-contextual behavioral advertising or targeted advertising through online tracking technology by clicking on the Cookie Settings link on our Site footer or in the mobile application and disabling all cookies that are not strictly necessary.

Do Not Track Signals. Some browsers have a “do not track” feature. It lets you tell websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. Our Sites are thus not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.

Chatbot Technology. We use chatbots to help provide customer service and support, including through the use of a virtual assistant.  A chatbot is a software application that mimics human conversations in text or voice interactions on our website or through our customer service hotline.  It enables the communication between a human and a machine, which can take the form of messages or voice commands.  The chatbot is designed to work without the assistance of a human operator.  It responds to questions posed to it in natural language as if it were a real person using a combination of pre-programmed scripts and machine learning algorithms.  When asked a question, the chatbot will answer using the knowledge database that is currently available to it. If the conversation introduces a concept it isn’t programmed to understand; it will pass it to a human operator.  If you use our chatbot service, we will collect any personal information you provide to use.  We will also create and store a transcript of your chat interaction with us which will be shared with and stored by our third-party service provider.  We use these transcripts and the information you provide for quality control, customer service, fraud prevention and security.

Global Privacy Control and Opt-Out Preference Signals. Some browsers or browser extensions also allow you to tell websites not to share your information for cross-contextual behavioral advertising through the “Global Privacy Control” or other opt-out preference signals.  If you have enabled Global Privacy Control or an opt-out preference signal on your browser or extension, we will honor such requests that can be recognized by our Site by disabling Analytics and Advertising cookies and similar technologies.  Please note that we may not be readily able to associate an opt-out preference signal with other personal information such as your email address. You will also only be opted out of online sales or sharing of personal information and will need to turn it on for each browser you use. 

Google Analytics. We use analytics services provided by Google Analytics. If you would like more information on how Google uses data when you visit or use our Sites, please visit www.google.com/policies/privacy/partners. If you would like to opt-out, Google provides a an opt-out tool which is available at https://tools.google.com/dlpage/gaoptout.

Our Sites may include links to other websites or applications whose privacy practices may differ from ours. If you submit personal information to any of those websites or applications, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or application that you use.

Security

We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.

If we become aware of a breach that affects the security of your personal information, we may provide you with notice as required by applicable law. To the extent permitted by applicable law, we may provide any such notice that we must provide to you under applicable law at your account’s email address. By using the Services, you agree to accept notice electronically.

This Sites is Not Intended for Children

We do not knowingly collect or store any personal information from anyone under the age of 16. If we become aware that we have collected or stored personal information from an individual under age 16, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to stew@stewbys.com.

Marketing Communications

Marketing Emails. You can opt out of marketing or advertising emails and newsletters by using the "unsubscribe" link or mechanism noted in communications you receive from us. You may also request to opt out of marketing or advertising emails by contacting us at unsubscribe@ldry.com.  Once we process your request, we will cease using the information for such purposes at no charge to you.  If you opt out of getting marketing messages, you will continue to receive messages from us about your relationship with us were permitted by law.

Phone Calls and Text Messages.  If you do not want to receive marketing phone calls or text messages from us, please inform us that you no longer want to receive calls from us when you receive a call from us or reply STOP to a text message from us.  You can also opt-out of telemarketing by contacting us at unsubscribe@ldry.com.

Processing in the United States

Please be aware that information we obtain about you will be processed in the United States or in other jurisdictions by our service providers or us. By using the Sites or our services, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own, as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States or other jurisdictions may be different from the laws in your country of residence.  The United States may not afford the same level of protection as laws in your own country.

California Privacy Rights

Shine The Light. If you are a California resident, this section applies to you.  The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at stew@stewbys.com and include “CA Shine the Light” in the subject line of your email.

California Consumer Privacy Act (“CCPA”).

This section applies to residents of California.

Sale or Sharing of Personal Information.  In the 12 months preceding the last updated date below, we have “sold” to or “shared” with (as those terms are defined in the CCPA) advertising/marketing/analytics partners the following categories of personal information:  identifiers, commercial information, geolocation data, and internet or electronic usage data.  We do not knowingly sell or share the personal information of anyone under the age of 16. 

 

Use or Disclosure of Sensitive Personal Information. In the 12 months preceding the last updated date below, we have not used or disclosed sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.

 

Disclosures for a Business Purpose.  In the 12 months preceding the last updated date below, we have disclosed the following categories of personal information to these categories of recipients for a business purpose.

  • Identifiers: service providers, affiliates, marketing/analytics/advertising partners, and government entities.
  • Protected Characteristics Under Federal or State Law: service providers, affiliates, and government entities.
  • Audio/Visual Data: service providers, affiliates, and government entities.
  • Commercial Information: service providers, affiliates, marketing/analytics/advertising partners, and government entities.
  • Education Information: service providers and government entities.
  • Internet or Electronic Usage Date: service providers, affiliates, and marketing/analytics/advertising partners.
  • Geolocation Data: service providers, affiliates, and marketing/analytics/advertising partners.
  • Professional or Employment Information: service providers and affiliates.
  • Education Information: service providers and affiliates.
  • Information described in Cal. Civ. Code § 1798.80(e): service providers, affiliates, and government entities.
  • Sensitive Personal Information: service providers and affiliates.
  • Inferences: service providers, affiliates, and marketing/analytics/advertising partners.

Notice of Financial Incentive. Based on your commercial activity and other factors, we may offer you various financial incentives such as discounts, comped services, and other special offers when you provide us with personal information (such as your name, email address, phone number, postal address, and date of birth) to sign-up for our loyalty programs. When you sign-up for our loyalty programs, you opt-in to receive financial incentives. Under our 24K Select and Landry’s Select Club programs, you can receive financial incentives (benefits) based on certain purchases and other activities related to gaming, dining, hotel, entertainment, and more. You may withdraw (opt-out) from receiving such financial incentives at any time by deactivating your loyalty program account. The financial incentives offered in connection with 24K Select and Landry’s Select Club are reasonably related to the value of a member’s data including the commercial activities of such member. We calculate the value of a member’s data based on various factors, including the member’s commercial activities and the expenses related to the offer, provision, or imposition of the financial incentives (benefits) to such member.

Your Rights Under the CCPA. Subject to certain exceptions and limitations, you have the following rights:

  • To request that we tell you (i) what personal information we have collected about you, (ii) the sources of that information, (iii) the business or commercial purposes for collecting, selling or sharing the personal information; and (iv) the categories of third parties to whom we have disclosed personal information.
  • To request that we provide you with a copy of your personal information.
  • To request that we delete your personal information.
  • To opt-out of: (i) the sale of your personal information; (ii) the sharing of your personal information for cross-context behavioral advertising or targeted advertising; and (iii) the use of .automated decision-making or profiling
  • To direct us to limit the use or disclosure of your sensitive personal information.
  • To correct inaccurate personal information that we hold about you.
  • To not be discriminated against for exercising any of your rights.

Exercising Your Rights. To exercise any of your rights, please use our contact form or call us toll free at 877-684-4388.  For all requests, you must provide us with your name, email address, phone number, and mailing address.  We will verify your identity by matching the information we have collected against the information you have provided.  Failure to provide the foregoing information may prevent us from processing your request.  If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.  In order to designate an authorized agent to act on your behalf, you must send a signed, written authorization to us.

Cookie-Based Opt-Outs for The Sale or Sharing of Personal Information.  We engage in online advertising practices (and certain analytics or similar activities) for targeted advertising and cross-context behavioral advertising.  To turn off targeted and behavioral advertising through cookies, please click on the “Cookie Preferences” link in the footer of our website and ensure that Analytics and Advertising cookies are disabled.  Please note that we may not be readily able to associate your personal information with your IP address or Device ID.  And that you will only be opt-ed out of online sales or sharing of data through targeted or behavioral advertising.   Refer to the “Exercising Your Rights” section above if you would like to extend your opt-out request beyond the online advertising practices described above. 

Virginia, Colorado, Connecticut, Texas, Oregon, and Utah Privacy Rights

This section applies to you if you are a resident of Virginia, Colorado, Connecticut, Texas, Oregon, or Utah.

We set forth above the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared. 

Your Rights.  Depending on your state of residence and subject to certain limitations and exceptions, you may have the following rights with respect to your personal data:

  • You have the right to request that we confirm whether or not we are processing your personal data and to access your personal data.
  • You have the right to obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format that allows data portability.
  • You have the right to correct inaccurate personal data that we hold about you, taking into account the nature of the personal data and the purposes of the processing of the data.
  • You have the right to request that we delete personal information that we have collected from you or obtained about you.
  • You have the right to opt out of the processing of the personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) automated decision-making or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

 

Exercising Your Rights. To exercise any of your rights, please use our webform or call us toll free at 877-684-4388.  For all requests, you must provide us with your name, email address, phone number, and mailing address.  We will verify your identity by matching the information we have collected against the information you have provided.  Failure to provide the foregoing information may prevent us from processing your request.  If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.  In order to designate an authorized agent to act on your behalf, you must send a signed, written authorization to us.

Appealing Our Decision.  If we refuse to take action on your request, you may appeal our decision within a reasonable period of time, not to exceed 90 calendar days from the date of your receipt of our response.  You may exercise your appeal rights by emailing us at stew@stewbys.com.  Please include your full name, the basis for your appeal, and any additional information to consider.

Cookie-Based Opt-Outs for The Sale or Sharing of Personal Information.  We engage in online advertising practices (and certain analytics or similar activities) for targeted advertising and cross-context behavioral advertising.  To turn off targeted and behavioral advertising through cookies, please click on the “Cookie Preferences” link in the footer of our website and ensure that Analytics and Advertising cookies are disabled.  Please note that we may not be readily able to associate your personal information with your IP address or Device ID.  And that you will only be opt-ed out of online sales or sharing of data through targeted or behavioral advertising.   Refer to the “Exercising Your Rights” section above if you would like to extend your opt-out request beyond the online advertising practices described above.  

Contact Us

If you have any questions about this Policy or our data practices, please email us at stew@stewbys.com.

Updates to Our Privacy Policy

From time to time we may change our privacy policy. We will notify you of any material changes to our privacy policy as required by law. We will also post an updated copy on the website where this appears. Please check our website periodically for updates.  The “Last Updated” legend above indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on any of our Site.